The REACH regulation related to registration, evaluation and authorization of chemicals has been effective since 1 Jun 2008, to a certain extent, it comes up with different degrees of influence impacting HK SMEs.
Based on a legal perspective, EU and EEA suppliers of articles which contain substances one or above SVHC (Substances of Very High Concern) in a concentration above 0.1% must provide sufficient information to their customers and on request to a consumer within 45 days of the receipt of this request. In a sense, to comply with relevant regulations, the importers will therefore request their suppliers to provide all goods’ chemical substances list. In addition, EU and EEA producers and importers of articles have to notify European Chemicals Agency (ECHA) if their article contains SVHC over 0.1% and its quantities in the produced/imported articles are above 1 tonne in total per year per company.

If you are one of the suppliers to EU countries, it is necessary to understand the regulation details, explain and share the preparatory work for registration with your buyers. For example, the suppliers can check SVHC lists regularly and develop an inventory of all substances of exported goods to buyers for notification purpose. Nowadays, there are 15 substances identified in the Candidate List of SVHC, and the authority is planning to add more substances into the list on 1 June 2009.